This document contains my rough notes after an initial read of the 95-page
draft. This doesn't reflect the opinions of The University of Washington, nor
DO-IT or any of its funding sources. I'm not even sure if it will ultimately
reflect my final opinions, but this represents my first reaction upon reading
this document recently on a long flight. To summarize, these standards and
guidelines are much more comprensive than the previous Section 508 standards,
but it's extremely challenging to sift through. Therefore many of my
observations focus more on organizational and linguistic issues than on
technical substance. As a person who spends a lot of time working to persuade
web and software developers to comply with standards and create accessible
content and products, I think it's critical that these standards be understandable.

Overall Structure

Previous standards included a normative standards document, and a
separate informative Guide to the
Standards which explained each standard in detail. The WCAG 2.0 assumes
a similar approach, by separating the WCAG 2.0 specification from a set of
supplemental documents. The current draft of the Refresh has normative and
informative content combined, which interrupts the flow of the document and
reduces its readability.

Related to the above, if Advisory content is integrated within the
standards document, how easily can it be updated? Presumably it would be
desirable to have this capability.

Having two Chapter 1's is weird.

Why does the 508 Chapter 1 start with "E" and the 255 Chapter 1 start
with "C"?

The overall outline of the original 508 standards would seem to still be
applicable to the Refresh. Why not preserve that outline for consistency
between versions?

Subpart A- General

Section 508 Application and Administration

Section 255 Application and Administration

Subpart B - Functional Performance Criteria (was Subpart C in
original 508, but I think good to bring forward as it presents the big
picture)

Subpart C - Technical Standards

Chapters 3 - 9

Subpart D - ICT Support Documentation and ICT Support Services (same
as "Information, Documentation, and Support" in original)

Subpart E - Amendments to the ADAAG

At a minimum, the technical standards should be organized
collectively.

A "General" sub-section (X.1) is provided for some sections, but not all.
It is unclear what the distinction is that deems a General sub-section to
be necessary. For example, Section 302 includes a General section, and
contains only one additional sub-section (302.2) plus an Advisory section.
In contrast, Section 306 does not have a General section, but includes both
an Advisory section and an Exception. Section 402 doesn't have a General
section either, but has three sub-sections. In most if not all cases, the
General section is self-referring and recursive (e.g., "406.1 ICT shall
conform to 406") and makes the standards difficult to read.

The self-referencing is particularly burdensome when there are deep
layers of sub-sub-sections. For example, 502.1 states that ICT with certain
characteristics "shall conform to 502". If we read on, we find in the next
section, Section 502.2, that text alternatives for non-text content shall
conform to 502.2.1 or 502.2.2. Following this there is an Adivsory section
before we finally get to 502.2.1, which at long last is an actual rule
(albeit a difficult to understand one).

If sections include exceptions, these are often stated before the rule is stated, as in Sections 405.2,
405.3, 413.2, etc. These should be reorganized so that exceptions to the
rule are stated only after the rule has been completely defined (including
both the rule itself and the Advisory content, if the latter remains in the
final document).

Other than the "General" sections, the sub-sections have linguistically
inconsistent labels. For example, there are:

Starting with a preposition (in the style established in the
Functional Criteria section), e.g., "302.2 WIthout Attachment of
Assistive Technology"

Commandments (e.g., "305.1 Not only color", "407.3 No Change of
Context from Change of Settings", "508.2.3 No Duplicate Attributes")

Audience

The audience is often unclear, and seems to switch back and forth. The
W3C approach, having WCAG, ATAG, and UAAG as separate documents makes much
more sense, so audience members don't have to struggle to figure out
whether a standard applies to them. Examples:

404.5 Visible Keyboard Focus Indicator. As explained in the Advisory
note, "When a user relies on the keyboard to ineract with content, this
provision requires a visible cursor so that the user can visually
determine the component with which the keyboard operations will
interact at any point in time." Who is responsible for providing this
visible keyboard focus indicator? The web developer? Or the browser
developer?

409 User Preferences and 410 Interoperability with Assistive
Technology are user agent standards. Previous and subsequent sections
are applicable to all ICT. Maybe it would help to sort by audience, or
at least to clearly identify the audience for each section.

410.4 Object Information - "programmatically determinable using
platform accessibility services" is probably understable to most
platform developers, but many others who are reading this will be
puzzled. I respect the need for platform neutrality, but it would help
if the Advisory note did mention a few accessibility services by name
to clarify what's being described here (e.g., MSAA, User Interface
Automation, IAccessible2, AT-SPI, OS X Accessibility API). Otherwise it
all sounds too euphemistic.

Advisory 501.1 states "This chapter is oriented toward authors, rather
than developers". However, this text is buried. It should be more
prominent, and communicated throughout the document, not just in this one
place.

Comments on Specific Chapters and Sections

E107 WCAG 2.0 Harmonization. I was hoping for better harmonization, i.e.,
"In order for ICT to meet the requirements of Section 508, it must comply
with WCAG Level AA, ATAG, and UAAG". If this document represents harmony,
it's very discordant harmony. The differences between WCAG 2.0 and the
Refresh document are much greater than the differences between WCAG 1.0 and
the original Section 508 standards, although E107 makes it possible to pick
a standard and focus on that, rather than try to comply with both. That
said, this section seems to contain redundant requirements by including the
phrase "all corresponding WCAG 2.0 Success Criteria and Conformance
Requirements". If ICT already meets WCAG 2.0 at Level AA, why does it also
need to meet "all corresponding WCAG 2.0 Success Criteria and Conformance
Requirements" in Chapters 4, 5, and 6? Is this not redundant?

202.11 "Minimize Photosensitive Seizure Triggers". This is the only item
in Section 202 that does not begin with either the word "With" or
"Without". For consistency, I suggest revising to "Without Triggering
Photosensitive Seizures"

The word "usable" appears throughout The Refresh but is not defined in
E111 or C109 (Definitions Sections).

301.1 "required by Chapter 1" does not specify which Chapter 1.

402.3 Alternate CAPTCHA requires "an alternative form of CAPTCHA using an
output mode for a different type of sensory perception". This does not
address accessibility for the deaf-blind or persons with
cognitive/processing disabilities

403.3 Resizable Text includes the Exception "Images of text, including
text used for captioning, are not required to support the ability to be
resized". Why not? Closed captions should resizable, and there are plenty
of examples of current technology supporting this (including YouTube).

405.2 Control Over Time Limits. Exception 3 says "When the time limit is
at least eight hours, no user control over the default time limit is
required". Why 8 hours? Why not 5? Seems arbitrary.

405.2.3.1 Expiration warning "The user shall be warned at least twenty
seconds before a time limit expires". Is twenty seconds enough? Is there
research to support this?

405.2.3.2. Multiple Extensions "The user shall be able to extend a time
limit at least ten times". Why ten?

406.2 Bypass Blocks of Content. The best practices described in the
Advisory section don't mention that a method should be visible, e.g.,
visible "same page" links, so keyboard-only sighted users and screen
magnification users can benefit

409.2 User Preferences - refers to a mode of operation that "uses user
preferences for platform settings". This is difficult to read - Consider
changing "uses" to "respects" or "honors", or some other change that fixes
this tongue twister.

Also, this sub-section only requires applictions to honor user
preferences for color, contrast, font type, and focus cursor. There are
many other accessibility-related user preferences, such as keyboard
features, mouse features, magnification, etc. Therefore, this
sub-section should not limit which user preferences are honored. I
recommend changing "for color, contrast..." to "such as color,
contrast..."

411 Compatible Technologies. This section, which applies specifically to
user agents but doesn't claim such, includes 411.2 User Interface
Components, which has sub-sections covering both ARIA and tables. It seems
odd that tables is the only specific user interface component that is
singled out here. Are tables the only possible UI component that are not
covered by 411.2.1 - 411.2.3?

413.4 Templates "When templates are provided with authoring tools, at
least one template for each template type shall conform to Chapter 5
(Electronic Documents)". Why only one? The "Accessible Template" is a
ghetto approach. All templates should be
accessible. Otherwise authors will use the inaccessible templates to create
inaccessible content.

502.2.2 - Each of the sub-sub-sections of this sub-section are the same
other than the object they describe. In 502.2.2.1, audio or video content
requires that "text alternatives shall provide descriptive identification
of the non-text content". 502.2.2.2 requires the same of Test or Exercise.
502.2.3 requires the same of Sensory Experience. Do we really need all
these sub-sub-sections, or can they be consolidated? Also, what exactly is
"descriptive identification"? It doesn't seem to be defined anywhere, and
502.2.2.1 has no Advisory content, which is where clarification is most
needed (e.g., is "descriptive identification" different from "video
description"?)

502.2.2.2 Test or Exercise. This is a very challenging requirement to
meet. Therefore, more examples are needed in the Advisory section,
especially examples demonstrating how to describe questions like "Based on
the following graph, identify..." and "Which of the following
images..."

502.2.2.4 CAPTCHA "text alternatives that identify and describe the
purpose of the non-text content shall be provided". Identifying the purpose
does not let the person in. If this requirement is intended to be met in conjunction with 402.3, the latter should be
cross-referenced here (and vice-versa).

502.3 Audio or Video Content. This is the more general A/V requirement,
but it's confusing here since A/V was covered previously (though less
comprehensively) under 502.2.2. The problem is once again organizational.
Some requirements are organized by feature (e.g., "Descriptive
Identification"), whereas others are organized by product category (e.g.,
"Audio or Video Content").

503.2.2 Forms. Requires labels, but what about other form elements that
increase accessibility such as fieldsets and optiongroups?

503.3 Logically correct reading sequence. This should also include
logically correct tab order. In the Advisory
section, it says "An example is a sidebar item that might reasonably be
read before, or after, or in the middle of the main content. Content
authors and developers have flexibility..." This might not be a problem for
screen reader users, but it's arguably not true of tab order for keyboard
users. In the U.S., tab order should reflect the standard reading
direction, which is left to right and top to bottom. Otherwise sighted
keyboard users, especially those using magnification, can easily get
disoriented.

503.4 This rule uses negative language ("shall not rely solely on those
characteristics..."), whereas most other rules are written in the positive.
Consider revising (e.g., "When providing instructions for understanding and
operating content, avoid instructions that rely solely on those
characteristics...")

504.2 "Text and Images of Text Contrast Ratio". This is awkward. What are
"Images of text contrast ratio"?

504.2.1 "Large-scale text" is hyphenated here, but not hyphenated in
504.2.2, nor in the Definitions section (E111.5). As a result, Ii tried
searching for "Large-scale text" and failed to find a definition.

504.3 Resize and Reflow Text. This section appears to include an Advisory
note (stylized in a grey box), but it doesn't say "Advisory".

505.2 Document Titles. "Documents shall have titles that describe topic
or purpose." What is a title? Is this referring solely to the title
element, or should all documents also have a top-level heading so the title
can be clearly visibly ascertained?

Advisory 603.2 says "This best practice is not a requirement." Is any
Advisory content a requirement?

Advisory 603.2 also says "An example where this would be a fundamental
alteration is a radio broadcast". Is this is exception? If so, shouldn't it be in an Exceptions section?

Could 603.3 (captions for interactive audio content) and 603.4 (captions
for video) swap positions, since 603.4 is arguably more common?